By: Dr. Julie Nelson | Licensed Psychologist.

The Association of State and Provincial Psychology Boards (ASPPB) has announced that its previous plan for a voluntary, “Step 2” section to the national exam for psychologists is no longer going to be optional. The new test will be combined with the existing test, which means that additions will be mandatory. The price will increase to $1200, up from the current $600.

The national exam is called the EPPP, or Examination for Professional Practice in Psychology, and is required by most regulatory boards as a hurdle for licensure in psychology. ASPPB, who owns the rights to the test, said the updated exam is planned for sale in January 2020.

The new strategy was first announced at the ASPPB Annual Meeting held October 18 in Hawaii, and communicated to regulatory boards in a letter from ASPPB CEO, Dr. Stephen DeMers. “The ASPPB Board of Directors, based on a number of factors, including feedback from our member jurisdictions and input from our legal counsel, has determined that the EPPP Part 2 is a necessary enhancement, and therefore an essential component of the EPPP,” wrote DeMers.

He explained that the original plan was for “encouraging, but not requiring” the use of the additional exam, called EPPP Step 2.

“However, as the Board considered the unintended implications of allowing jurisdictions to choose a time frame and mechanism to adopt the EPPP Part 2,” he wrote, “the Board determined that the integrity and legal defensibility of the EPPP depended on treating Part 2 as an essential and integral part of the assessment of competence to practice for all those using the EPPP as a requirement for licensure.”

In 2016 ASPPB had announced the Step 2 exam and objections mounted, mostly from student and early career psychologist organizations.

Last year in Louisiana, Dr. Amy Henke, then a Director on the Executive Council of the Louisiana Psychological Association (LPA) and Co-Chair of the LPA Early Career Psychologists Committee in LPA, put forth a Resolution to oppose the Step 2 for Louisiana, which passed unanimously. Dr. Henke is now serving on the state psychology board.

Objections, from Henke and others, involve technical and scientific issues, but also the criticism that there is no problem that the new test needs to solve. “There is no evidence that the public is facing some sort of previously unheard of crisis in terms of safety from currently practicing psychologists,” said Dr. Henke in 2016.

Who is ASPPB and How Did We Get Here?

The ASPPB is listed as a private, non-profit, 501(c) tax-exempt corporation located in Tyrone, Georgia. The company states its mission is to “Facilitate communication among member jurisdictions about licensure, certification, and mobility of professional psychologists.”

ASPPB grossed $5,933,473 in 2016 and listed assets of $8,954,240.

The “members” appear to be 64 representatives from regulatory boards from across the United States and Canada. The boards pay dues to be a member of ASPPB.

While many members are government officials, ASPPB does not follow open meetings laws. Deliberations and decisions are private. “If you are not a member or staff of an ASPPB Member Psychology Regulatory Board or an individual member, you are not eligible to access this section of our website,” they write. Their conferences are also members only.

ASPPB’s mission is to facilitate communication, but it also owns the intellectual property rights to the EPPP and the data generated by the testing program, which they seem to have acquired in or around 2013.

In a Letter of Agreement from ASPPB to the boards in late 2012, ASPPB wrote that the EPPP is “made available as a service to psychology licensure boards that are ASPPB members in good standing as signified by payment of membership dues.”

ASPPB’s main income producing product is the national exam for psychologists, which brings in about $5,000,000 in gross sales each year. They have a few other products, such as the Psychology Interjurisdictional Compact (PSYPACT), a service to coordinate psychologists working across state lines.

While state boards are not required by law to use the EPPP, they uniformly do, since most licensing laws require a national exam.

Around 2012 ASPPB appears to have embraced a more aggressive corporate strategy. An insider told the Times, “In 2010 or somewhere around that time they were in New Orleans and they implied that they would be making a lot of money on the new test.”

In 2012, ASPPB acquired the rights for the national exam, taking over from Professional Examination Service (PES). In 2013 ASPPB wrote the boards that their contracts with PES were being “replaced with a contract between your jurisdiction and the Association of State and Provincial Psychology Boards.”

In that letter, ASPPB officials said, “ASPPB and PES have agreed that it would be simpler and more appropriate for ASPPB to contract directly with the 64 psychology regulatory agencies that are members of ASPPB.”

ASPPB said that the change would be “mutually beneficial because ASPPB can now provide a simplified agreement that is more specific to the needs of psychology licensure boards. In addition, the renewal of contracts is expected to be more efficient…” And, “Finally, as voting members of ASPPB, each jurisdiction exercises more oversight of this important examination service by contracting directly with ASPPB for examination services.”

At the same time, ASPPB increased candidates’ exam fees from $450 to $600.

ASPPB’s plan to create additional testing products may have been in place as early as 2010. One undisclosed insider thinks the corporate objective for ASPPB is to be a central source for regulation of psychologists. “They want to ultimately do all the licensing and regulating for psychology,” said the insider. “They want to regulate all the telepsychology.” And, “They want to be the Walmart.”

In 2013 ASPPB officials were instrumental in conducting and designing the 5th International Congress on Licensure, Certification, and Credentialing of Psychologists, held in Stockhom, which focused on “… defining professional competence rather than specifying curricula or training requirements,” reported the Norwegian Co-chair. The invitation-only conference was primarily funded by ASPPB.

Dr. Emil Rodolfa, Chair of the Implementation Task Force for the EPPP Step 2, and past president of ASPPB, facilitated at the Congress. His goal, according to reports published by the Co- chair, was to address assessment and credentialing issues for competence for psychologists.

ASPPB’s Profitability

ASPPB brings in $5 plus million yearly for its testing products, the main profit source being the EPPP.

Exams and related fees grossed $5,296,421 for 2016, or 89% of all ASPPB venues. In 2015 this amount was $4,775,213 and in 2014 it was $4,826, 421.

For 2016 they list 12 employees, the most highly compensated is Dr. DeMers, at $243,842. Another four fall between $131,949 and $125,860. Others are modest.

For exams in 2016, they claim expenses of $1,859, 374 against revenues of $4,916,406 for exams, a profit margin of 38 percent. One of the two major expenses is to Pearson Vue, Minneappolis for $956,598. The second major expense appears to fall under “Other salaries and wages,” and comes to $906,995. No employee names are given and it is not clear who receives this money.

ASPPB claims a large expense for travel. In 2016 the corporation reported $867,217 spent for travel and also another $200,583 for conferences.

Travel expense is consistently high. For example, in 2014 they reported $863,340 for travel and $222,083 for conferences. According to various other records Dr. DeMers traveled to Paris, Oslo, New Zealand, Milan, and to Beijing, to meet with international colleagues.

Of note is that ASPPB does not report payments of travel or entertainment for federal, state or local public officials on the tax returns. However, it appears to be a regular occurrence and openly discussed. In a June 2016 a review of the Louisiana State Board of Examiners of Psychologists (LSBEP), the Legislative Auditor wrote:

“Based on information provided by the Board, the former executive director may have improperly charged $2,343 to the Board for airfare, hotel, baggage, and parking fees related to participation in Association of State and Provincial Psychology Boards (ASPPB) committee meetings during October and November 2014. ASPPB stated it pays for flights, hotel rooms, and associated travel expenses for committee meeting participants, either directly or through reimbursement.”

Charging to Fix What Isn’t Broken

Dr. Henke and the 2016 LPA Resolution to oppose the new test point out that multiple checks on competency already exist for psychologists and appear to be working to protect the public.

“Trainees are already held to high standards through a variety of benchmarks,” Dr. Henke wrote in the Resolution, “including but not limited to: APA approval of doctoral programs, multiple practicums where competency is repeatedly assessed, completion of formal internship training (also approved and regulated by APA and APPIC), and supervised post-doctoral hours obtained prior to licensure. There is no evidence to suggest this is not sufficient for appropriate training.”

Henke and others have also pointed to multiple hurdles that candidates already must clear, including two years supervision, a written exam, oral exam, background check, and jurisprudence exam. Additionally, the law allows the board to require additional physical and psychological assessments whenever needed.

However, Dr. Rodolfa questions if these standards are enough, saying that supervisors have “… difficulty providing accurate evaluations of their supervisees to others who may have to evaluate the supervisee’s competency.”

Dr. Henke has also said, “I am particularly concerned about regulatory boards encroaching ownership of training standards. The goal of a regulatory board, in my personal opinion, is to provide the least restrictive amount of guidelines possible in order to protect the safety of the public.”

Dr. Rodolfa disagrees and said, “Licensing boards have a mandate to ensure that the professionals they license are competent. Competence is comprised of the integrated use of knowledge, skills, attitudes and values.”

In the LPA Resolution, Dr. Henke said about the new test, “There is no scientific data that support better outcomes regarding patient safety or quality of care. Given that psychologists are uniquely trained to design and create tests, it is concerning that this test is being proposed without any indication of its necessity for either the field or for the safety of the public.”

Henke and others point out that the evidence from disciplinary statistics suggests that problems are very low.

For the most recent year with records, 2016, total reported disciplinary actions across the U.S. and Canada dropped 32 percent from 2015. There were 130 disciplinary actions nationwide in 2016, the lowest number in the last five years. This from the ASPPB Disciplinary Data System: Historical Discipline Report. This number gives a rate of .001 based on 106,000 psychologists nationwide.

Rates of disciplinary actions for psychologists are consistency low. In 2015 there were 191 actions, in 2014 there were 170, and in 2013 there were 238. Rates remain around 1 or 2 in 1,000.

Louisiana’s rate is similar to the national average. Based on reported disciplinary actions for a five-year period, there were eight separate disciplinary actions by the Louisiana State Board of Examiners of Psychologists (LSBEP) from 2010 to 2014. (Six of the eight involved child custody.) The rate of 1.6 disciplinary actions for approximately 700 psychologists, is consistent with the national rate 1 or 2 per thousand.

Adverse actions and malpractice payments for psychologists and/or medical psychologists in Louisiana over the period of 2004 to 2016, based on National Practitioner Data Bank. Five medical malpractice payments were reported. The lowest settlement was $10,000 and the highest was $170,000.

For the same 11-year time period, 21 “Adverse Actions” which include board actions, occurred. This is about 1 in 400 for psychologists and medical psychologists, and an estimated 1 in 8,000 if using patients/clients.

“There is no evidence that the public is facing some sort of previously unheard of crisis in terms of safety from currently practicing psychologists,” Dr. Henke has said, and she bases this on facts that even ASPPB helps to gather in their report, ASPPB Disciplinary Data System: Historical Discipline Report.

In her LPA Resolution, Dr. Henke wrote about the EPPP2: “There is no scientific data that support better outcomes regarding patient safety or quality of care. Given that psychologists are uniquely trained to design and create tests, it is concerning that this test is being proposed without any indication of its necessity for either the field or for the safety of the public.”

Some say that the technical standards used by ASPPB are insufficient. In 2009, Brian Sharpless and Jacques Barber authored “The Examination for Professional Practice in Psychology (EPPP) in the era of evidence-based practice,” for Professional Psychology: Research and Practice.

“Professional psychology has increasingly moved toward evidence-based practice,” said the two authors. “However, instruments used to assess psychologists seeking licensure, such as the Examination for Professional Practice in Psychology (EPPP), have received relatively little empirical scrutiny.” They write “there is a paucity of criterion, predictive, and incremental validity evidence available.”

Dr. DeMers responded in the same journal attempting to clarify issues and giving some information not published. He agreed with some of the recommendations, according to the summary of his article.

Industrial-Organizational Psychologist Dr. William Costelloe, Chair of the I-O and Consulting Psychology Committee of LPA, told the Times, “… predictive validation studies must be conducted.” This type of research proof is not optional, he said. “Well conducted, scientifically based predictive validation studies must be conducted if the EPPP2 is intended to be used as a selection tool,” Costelloe said.

Henke and LPA also point to the issue that the test costs fall on the backs of those least able to shoulder them, new psychologists. According to the American Psychological Association these psychologists carry on average between $77,000 and $200,000 in student debt.

The current EPPP contains 225 items and costs $600 for 225 items, with a four-hour time limit. Physicians pay $605 for an eight-hour exam, and Social Worker candidates pay about $250 for a 170-item exam.

[Julie Nelson is a licensed psychologist, journalist, organizational consultant, and publisher of the Times. She also holds other various positions in the community. However, her opinions here are those of her own, and do not represent any group or association. She and the Times receive no compensation other than paid advertizing. Email her at drj@drjulienelson.com, ––she welcomes feedback.]

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